Privacy Statement

This is the Privacy Statement of East Lane Advisory Limited, registered at Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong S.A.R., under registration number 77255696 (“East Lane”).  This document explains how East Lane collects, handles, stores, and processes personal data.

References to “Data Protection Legislation” refer to the Personal Data (Privacy) Ordinance (Cap.486),  the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Hong Kong Data Protection Act 2018 (DPA 2018) (and regulations made thereunder), and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended, together with all other applicable legislation relating to privacy or data protection, including any statute or statutory provision that amends, extends, consolidates, or replaces the same.  The terms “personal data,” “data subject,” “controller,” “processor,” and “process” (and their derivatives) shall have the meanings given to them in the Data Protection Legislation.

How We Use Your Personal Data

East Lane holds information that helps financial institutions, corporates, professional services firms, law enforcement agencies, regulators, and other clients (“East Lane Clients”) to perform due diligence and other research activities in accordance with their legal or regulatory obligations and risk management procedures.  East Lane also holds information specifically about East Lane Clients which it collects in order to provide its services and satisfy its legal and regulatory obligations.

East Lane may also process information for several other business purposes.  Examples of the types of uses of such information include:

• Providing Services: To deliver the services you have requested and to operate your  client account(s)
• Compliance and Legal Obligations: To comply with legal or regulatory requirements, including conflict checks, billing assessments, anti-money laundering  checks, fraud prevention, and compliance screening
• Business Operations: To improve its services, carry out statistical analysis,  perform quality control, and manage insurance and administrative tasks
• Marketing and Communication: To follow up with you for further assistance and send invitations to briefings or marketing communications unless you opt out
• Business Transactions: In the event of a sale or restructuring of its business, subject to confidentiality obligations

Information That We Collect

The information referred to above includes personal data, which means information that can be used to identify a natural person, including (but not limited to) the following types of personal information:

• Contact information, such as home or work addresses and contact details (including mobile telephone number)
• Information  obtained from the instructions of East Lane Clients
• Details of any complaints or concerns raised
• Employment status
• Financial information (including bank details, assets, tax rates, and information related to investments)
• Date of birth, marital/civil partnership status, details of dependants, and next of kin
• Information collected from publicly available sources, such as sanctions lists, media coverage, social media platforms, and Politically Exposed Persons lists
• Information collected from international and national litigation records, media coverage, social media platforms, aggregated corporate databases, and other investigative sources such as specialist search engines, public records databases, electoral registers, and databases of IP addresses and domain names
• Information about an individual’s professional qualifications
• Any  other information provided by East Lane Clients in the course of providing its services
• Information obtained from third parties, such as information verified when validating details supplied by East Lane Clients.  This may include fraud prevention agencies and information from publicly available sources
• Information provided by its advisers and contributors who assist in providing its services
• Technical information, including Internet Protocol (IP) address, usage information, browser type and version, time zone setting and location, language, browser plug-in types and versions, operating system, platform, and other technologies on the devices used to access the East Lane website

Some of the information that East Lane collects may include special categories of personal data (such as information about racial or ethnic origin, criminal or alleged criminal offences, or health and lifestyle).  The processing of such data may be necessary for the establishment, exercise, or defence of legal claims.

East Lane may be prevented from providing services where there is a failure to provide the above information.

Lawful Grounds for Using Information

East Lane has described the purposes for which it may use information.  It is permitted to process such information in compliance with the Data Protection Legislation by relying on one or more of the following lawful grounds:

• Consent: Where it has obtained your explicit consent for specific purposes
• Contractual Necessity: Where processing is required to perform a contract or take steps prior to entering into a contract
• Legal Obligation: Where processing is necessary to comply with a legal duty
• Legitimate Interests: Where processing is necessary for its legitimate business interests, including:
  • Providing and improving services
  • Enhancing security and fraud prevention
  • Responding to complaints
  • Marketing communications, unless you object

How We Share Your Personal Data

East Lane keeps all information confidential.  However, in order to provide its services and meet East Lane Client needs, East Lane may share any information with its agents, contributors, advisers, contractors, counterparties, and support service or data providers, wherever located.

East Lane may also provide third-party service providers access to East Lane Client information where they support or provide services.  East Lane will ensure that if it shares information with, or provides access to, third-party service providers, any such disclosure or access is incompliance with Data Protection Legislation.

The recipients, or categories of recipients, of information that East Lane holds may be:

• Any revenue service or tax authority if obliged to do so under applicable regulations.  For Common Reporting Standards and FATCA, East Lane may also be required to report your account(s) to the relevant tax authorities
• Advisers (including, but not limited to, accountants or other professional advisers) where authorised to do so
• Regulators, courts, and authorities in connection with their duties (such as crime prevention)
• Fraud prevention agencies, who will use it to prevent fraud and money laundering and to verify identities.  These agencies may also enable law enforcement agencies to access and use your information to detect, investigate, and prevent crime
• Third-party service providers who support or provide services to East Lane
• Anyone to whom East Lane may transfer its rights and/or obligations under this Privacy Statement
• Any other person or organisation after a restructure, sale, or acquisition

If East Lane or a fraud prevention agency determines that an East Lane Client poses a fraud or money laundering risk:

• East Lane may refuse to provide the requested services, or may stop providing existing services
• A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, which may result in others refusing to provide services, financing, or employment

Cross-Border Transfers of Personal Data

Information in East Lane’s possession may be transferred to other countries (including those outside the European Economic Area) for any of the purposes described in this Privacy Statement.

These countries may have differing (and potentially less stringent) laws regarding confidentiality, and such information could become subject to the laws and disclosure requirements of these countries, including disclosure to governmental bodies, courts, regulatory agencies, and private persons as a result of applicable governmental or regulatory inquiry, court order, or similar process.

When East Lane, or its permitted third parties, transfers information outside the European Economic Area, it or they will impose contractual obligations on the recipients of that data to protect the information to the standard required in the European Economic Area.  East Lane may also transfer information where:

• The transfer is to a country deemed by the European Commission to provide adequate protection of information
• East Lane has received consent for such transfer
• Such transfer is otherwise permissible under Data Protection Legislation (for example, if required by law

Your Rights Regarding Your Personal Data

Data subjects have several rights concerning their personal data, which include the right to:

• Request access to, or a copy of, any personal data held about them
• Request the rectification of their personal data if they consider it to be inaccurate
• Request  the erasure of their personal data if they believe East Lane no longer has the right to hold it
• Object to their personal data being processed for a particular purpose or request that it stops using their information
• Request not to be subject to a decision based on automated processing and to have safeguards put in place if being profiled based on their personal data
• Ask for the transfer of their personal data to another party where technically feasible and required by applicable regulations
• Withdraw any consent they have previously given for the processing of their personal data
• Request that marketing communications be stopped or started at any time

Any request for access to or a copy of personal data must be made in writing.  East Lane will endeavour to respond within a reasonable period and, in any event, within one month in compliance with Data Protection Legislation.  East Lane will comply with its legal obligations regarding the rights of data subjects.

If you would like to contact East Lane regarding any of the rights set out above, please do so using the contact details in the “Contacting Us” section below.

Retaining Your Personal Data

East Lane will retain the information it collects on its systems or with third parties for as long as required for the purposes outlined above or to comply with any legal obligations.  This will involve East Lane regularly reviewing its files to ensure that information is accurate, up-to-date, and still required.

If you terminate your relationship with East Lane, if a matter concludes, or if you choose not to proceed with a matter, East Lane may still keep your information.

Contacting Us

• Write to East Lane Advisory Limited at Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong S.A.R.
• Email: info@eastln.com

Updates

This Privacy Statement was updated in January 2025.  East Lane reserves the right to amend this Privacy Statement from time to time to reflect changing legal requirements or its processing practices. Any such changes will be posted on this website and will be effective upon posting.